PV Direct-Marketer Conflicts
— mapped across 30 countries.

1. Context and methodology

This study originated from a concrete German forensics case: a 9.998 MWp solar plant (Bavaria, commissioning 16 July 2024) has demonstrably been losing revenue since early 2025 because its direct marketer (DV) curtails the plant via software setpoint (RPC, Remote Power Control) — partly legitimately under §51 EEG 2023 (negative hourly-average spot price), but partly also during hours with clear sun and positive or slightly negative spot price without 3-hour cluster. This shadow curtailment is not covered by the marketing contract — it acts as balancing-circle self-optimisation by the marketer at the plant's expense.

Stromfee.ai proves these shadow curtailments forensically (4-mirror methodology: plant × market × grid × marketer, cross-reference at 15-minute resolution). The question of this study: In which other countries do structurally similar constellations exist — and is comparable forensics software already available there?

2. World table · 30 countries at a glance

Sorted by category. Click on the country code to open live power prices on stromfee.ai/energy.

3. Category A · Strong parallels to DE shadow curtailment

4. Category B · Weak parallels (different market structure)

5. Category C · No parallel

In six surveyed countries there is no relevant market-structure parallel to the DE shadow-curtailment problem because the market is transparent (DK, SE, NO, AU market), contractually accepted (AR), too small (TH, CA-QC) or the data monopoly is so hermetic that forensics is impossible (VN, CN State Grid SCADA, KR substation stop).

6. China · Special chapter

6.1 Curtailment crisis 2.0 (2024–2025)

China had the first curtailment crisis in 2015–2016 (up to 30% curtailment in Xinjiang/Gansu/Qinghai). UHVDC expansion lowered national rate to 2% by 2020. Crisis 2.0: according to NEA, H1/2025 rose to 6.6% (vs. 3.9% H1/2024). Driver this time not the West alone but distributed PV penetration in load centres. Qinghai 15.2%, Tibet/Xinjiang above NEA 5% threshold. S&P Global expects no significant reduction before 2027.

6.2 Actors

• NDRC — economic regulator, sets tariffs and market rules (Document 136)
• NEA — sector regulator, defines minimum off-take hours and curtailment thresholds
• SGCC (State Grid) — operates 88% of the national grid, dispatch authority
• CSG (China Southern Power Grid) — analogous for Guangdong, Guangxi, Yunnan, Guizhou, Hainan
• Provincial grid companies — operational curtailment commands

6.3 Document 136 (NDRC, 9 Feb 2025)

Most important regulatory upheaval in 10 years. Key points: PV/wind commissioned from 1 Jun 2025 lose fixed guaranteed tariff → annual CfD auction per province + spot market remainder. Existing plants keep grandfathering but must be exposed to spot market mechanisms. As of 15 Oct 2025: only 18/31 provinces have finalised plans.

6.4 Negative prices and Stromfee need

Shandong May 2025: 22 hours of negative prices in a row. Solar average selling price April 2025 only 0.02 CNY/kWh (≈ 0.25 c€/kWh) versus coal benchmark 0.35-0.45 CNY/kWh. First Shandong auction: solar prices 32% below settlement average. With Document 136, marketer shadow-curtailment risk emerges structurally for the first time — but no Chinese Stromfee equivalent. Market entry barrier: state data control, IPPs avoid public confrontation with state monopoly.

7. India · APTEL precedent 2021

India has the procedurally most advanced curtailment jurisprudence of the region. The APTEL ruling of 2021 (TANGEDCO/Tamil Nadu, Petition 287/MP/2019) sentenced the Discom to pay 75% of the PPA tariff as deemed-generation compensation for curtailment outside genuine grid-security reasons, plus 9% interest. This is the most direct legal analogy to the German case in the region.

International benchmark for German operators: The APTEL 75%-of-PPA-tariff standard can be cited in legal briefs as an international benchmark for compensation claims.

8. Global software landscape & market gap

The global market for solar asset-management software is estimated 2025 at between $1.2 and $2.5 bn (CAGR 12.9-15.4% to 2033). Global installed PV capacity exceeded 2.3 TW in 2025 (IEA). The software landscape splits into 5 functional layers:

9. Stromfee positioning · 4-mirror methodology

+-----------------------+      +-------------------------+      +-------------------------+
| Mirror 1: Plant       |      | Mirror 2: Market        |      | Mirror 3: Grid          |
| (meteocontrol VCOM,   |  X   | (ENTSO-E, EPEX spot,    |  X   | (Netztransparenz, TSO,  |
| inverter, Open-Meteo) |      | EEG-MW, AW, §51 block)  |      | rd_events)              |
+-----------------------+      +-------------------------+      +-------------------------+
                                          X
                              +-------------------------+
                              | Mirror 4: Marketer      |
                              | (Trianel-MSCONS,        |
                              | Pos-001/002, SoK24)     |
                              +-------------------------+
                                          |
                                    4-MIRROR FORENSICS
                                          |
                              Cash damage in EUR,
                              causal curtailment classification
    

The named providers deliver mirror 1 (Power Factors, Meteocontrol, SenseHawk), mirror 2 (Pexapark, Modo, enmacc, Montel) or mirror 3 (internal TSO SCADA tools) — but no one crosses all four mirrors with mandatory verification down to contract clause level (V24PV033-style contracts with max(AW,MW) calculation, 3h/4h/6h block choice, curtailment floor).

Stromfee USP: operator-centric buyer position free from conflict of interest with DV large customers. This is a structural differentiation that Power Factors etc. cannot build without large-customer conflict.

Addressable market: DE alone 4,000-8,000 PV plants >1 MWp × €3-6k/year forensics subscription = €12-50 M/year. Globally ~400-600 GW under DV/off-taker contracts → triple-digit M€ range. Small against $1.2-2.5 bn APM software world, but clearly delineated premium niche segment with high defensibility moat.

10. Top-5 expansion recommendation

NOT prioritised: 🇺🇸 ERCOT (market maturity high but US legal complexity + data cost), 🇨🇳 China (political + data wall), 🇲🇽 Mexico (state as opponent), 🇻🇳 Vietnam (no data access).

11. LEAP-71 falsification audit

12. Sources